Unfortunately, over the past 10 years we have witnessed a resurgence of tax shelter activity that has caused great damage to the integrity of our tax system. We have many cases under examination and many others in various stages of litigation. In working these cases, we must keep in mind that the economic substance doctrine is not a general antiabuse rule that can be raised to attack every transaction that the IRS does not like. On the other hand, taxpayers and practitioners should not forget that the doctrine is an indispensable tool which the IRS must be able to employ, to challenge transactions where the tax results appear inconsistent with Congressional intent and common sense. What this means is that in appropriate cases, the IRS will use all of the tools at its disposal to combat abusive tax shelters, including the economic substance doctrine.